Website Privacy Policy

Our Privacy & Cookie Statement

This is the Privacy and Cookies Policy for Motley Fool Asset Management, LLC website (“we”, “us”, “Motley Fool Asset Management”, “MFAM” and “our site”). A privacy notice will also be included within the investment documents for MFAM Funds, but this Privacy Policy (as modified from time to time through procedures described below) applies to shareholders (or potential investors) who use the mfamfunds.com website for information or transactions. We are committed to protecting and respecting your privacy.

This Policy and any other documents referred to in it explains:

• Information we collect about you
• Our legal bases for processing your information
• How we use your information
• Promotional updates and communications
• How we store and retain your information
• Cookies and other technologies
• Cookie Removal
• Information sharing and disclosure
• Security and protection of your information
• Child safety
• International Users
• Update or correct your information
• Opt out or close your account
• Changes to this policy
• Contact us

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using our website and our services, you acknowledge you have read and understood this privacy policy.

We know that while you as investors (i.e., “you”) are entrusting us to manage your investment, you are also entrusting us with the privacy and security of your personal information. We take that trust seriously.

In Summary: This Privacy Statement applies to the operations of Motley Fool Asset Management, which products are directed at investors in the United States of America.  It explains how MFAM collects, use and safeguards your personal data. By using the sites and providing us with personal data you are consenting to our processing data in the United States and under its laws.

Data handling practices and rules may differ from country to country. Each Motley Fool entity (e.g., The Motley Fool Limited, which operates fool.co.uk in the United Kingdom, or The Motley Fool, LLC, our parent company that provides newsletter services) may have different policies, which will apply to (and be stated on) its sites.

If you are a resident of the European Union or anywhere other than in the U.S., Motley Fool Asset Management services are available only to investors and prospective investors who reside in the United States (including the territories of Guam, Puerto Rico, and the United States Virgin Islands). MFAM generally does not manage money for individuals residing outside the United States, even if they are United States citizens or lawful permanent residents, except to investors with United States military APO or FPO addresses.

The information on this site is intended solely for U.S. residents. Nothing on the Motley Fool Asset Management site should be considered a solicitation in any jurisdiction where the offer, solicitation, purchase, or sale would be unlawful under the securities laws of such foreign jurisdiction or the United States.

While we do our best to protect your personal information, Motley Fool Asset Management cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.

What does all of this mean? Just as in the investing world, you must protect yourself. You are responsible for maintaining the secrecy of any password and/or account information. Please be careful and responsible whenever you are online, especially when using a computer that other people can use also or if you are on an unsecured network.

1. Information We Collect About You

We will collect and process the following personal data from you:

1.1 Information you give us

This is information about you that you give us directly when you interact with us.

1. Signing Up for Content Delivered via Email: When you sign up for news or other content delivered by email, we will ask for your email address. We may also ask for your name as well as capture your IP address.
2. Becoming a Shareholder: When becoming a Shareholder in one of our Funds, we need to know the sort of information typically used for financial transactions, such as your name, address, telephone number, social security number, and banking information, including wire transfer instructions. We encrypt all of this information using Transport Layer Security (TLS), the replacement for the deprecated Secure Socket Layers (SSL) technology.
3. Other Services: We may also ask for additional information when providing other services. If you don’t want to give us the information requested, you certainly don’t have to, but you will not be able to take advantage of such offerings. For example, if we launch a text alert feature, we wouldn’t be able to send you any alerts unless you provide us with your mobile number. Or, you may not be able to gain access to certain areas of our site unless you register and/or subscribe. On occasion, we may also ask you for other personal information in connection with surveys, contests or other promotional offers running on our site, but again, your participation in these features is purely voluntary.
4. Information About Others: If you use our recommendation service to email one of our articles to a friend, you will need to provide us with your friend’s email address and your email address as a return address. We will automatically send this person a one-time email, with the recommended article attached, as well as invite your friend to visit and register with our site. We will not use these email addresses for any other purpose.

1.2 Information we collect about you from using our site:

1. While on our site, we automatically log certain information about how you’re using our site. This information may include the URL that you just came from, your IP address (or a partially anonymized IP address), details about your browser, device, OS, or probable location, and the pages you visit while on our site.
2. When you visit our sites we will assign you a unique identifier so we can recognize you across different portions of our sites. You may have one or more of these, and they may persist between visits to our sites, so we can recognize you when you come back.
3. We may place a tracking mechanism, such as a pixel or web beacon, on pages or components of our site. This enables us to record in our server logs that a specific user id has visited a particular page. This data allows us to analyze and determine our audience’s behavioral characteristics, which helps us to optimize our site, advertisement placement, and marketing focus.

1.3 Information we receive from other sources:

1. We may place a tracking mechanism on pages or components of some of our partners’ sites so that when you use services from our partners, we can record that a specific user ID visited that service. This helps us analyze our audience in a manner similar to when you visit our own site.
2. We have also engaged third-party companies to gather and process information about our users on our behalf, to help us improve our sites and find new members. These companies will combine our data about how you visit our websites with information that they have collected from outside our sites and provide it to us so that we can optimize your experience across our sites, across multiple devices, and based on your interests.

To learn more about this behavioral advertising, including information on how to opt-out, please see our Opt Out or Close Your Account section.

1.4 Business purposes and categories of personal information we collect:

Our business is constantly evolving to create and deliver the most relevant products and services to you. We collect a variety of different personal data for numerous business reasons. For a full listing of those reason, please see Section 3.

1.5 Categories of third parties from which we collect personal information:

We collect information about you from third parties that have information about you or about people that exhibit similarities to the data we have collected about you. For more information, see the How We Use Your Information section of this privacy statement.

We collect personal information about you from the following categories of third parties:

          -Data Enrichment providers

          -Fund Administration

          -Brokers (if you hold your MFAM Funds through a brokerage account)

          -Shareholder Communications (for proxy or Fund related communications)

2. Our Legal Bases for Processing Your Information:

We can collect and process your data under one of the following legal bases for our use.

2.1 Consent

We can collect and process your data with your consent.

• For example, if you have given your consent to receiving marketing material from us at the point we collected your information.

2.2 Contractual Obligations

We need your personal data to comply with our contractual obligations.

• For example, if you have subscribed to one of our services, we use your personal data to fulfill, and deliver that service to you.

2.3 Legal Compliance

If the law requires us to, we may need to collect and process your data.

2.4 Legitimate interest

We may require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom, or interests.  We will use this information in our legitimate interests, where we have considered these are not overridden by your rights.

3. How We Use Your Information

3.1 Business Purposes for Which We Collect and Use Personal Data:

When we have a legal basis for collecting your personal information , we  do so from a variety of sources, including without limitation your explicit input and interaction on our web sites,   through our advertisements on other web sites, and through third parties that have information about you or about people that exhibit similarities to the data we have collected about you. We may combine your data with anonymized, aggregated data to draw inferences about you or your interests. We use all this data to make our site and our advertising relevant to you.

In order to maintain relevant and accurate personal information about you, we may disclose your  personal data, browsing habits, or other identifying information to service providers and third parties, and in return they may provide us with additional email addresses, names, physical addresses, other identifiers, browsing habits, and demographic information, which may include education level, income, investment portfolio, race, gender, personal interests you have told them about, and other personal details they infer about you. To read about your options for opting out of this data sharing, please see our Opt Out or Close Your Account section of this privacy statement.

3.2 Categories of Service Providers to Which Personal Data is Disclosed:

We utilize service providers to process personal information for a variety of purposes that would be difficult for our business to conduct on our own. In some states, these types of external companies are called service providers. We disclose personal information about you to the following categories of service providers in order to process data for us:

• Data verification providers, like the US Postal Service
• Content delivery providers, like Mailchimp or Hubspot
• Traffic monitoring and analytics providers, like Google Analytics

3.3 Categories of Other Third Parties to Which Personal Information  May Be Sold; and the Business Purposes for such “Sales”:

 If you are a California resident, some of our disclosure of personal information is considered a sale of data even if we don’t receive something of monetary value in exchange. We share personal information in this type of “sale” with the following categories of third parties:

• Marketing analytics companies, like Google
• Data enrichment firms, like Infogroup

  We share personal information with third parties in this type of “sale” for the following business purposes:

• Advertising: To deliver relevant advertising to you and to measure and optimize the effectiveness of our advertising
• Marketing: To keep you informed about products and services similar to the ones you express interest in – on our site and elsewhere on the internet
• Research: To better understand our members, potential members, and visitors so we can improve our products and services, and better target how we deliver information about those products and services.

4. Promotional Updates and Communications

Where permitted by one of the legal bases above, we will use your personal information for marketing analysis and to provide you with promotional update communications (e.g., by email) about our products/services and those of our business partners.

To read about your options for opting out of marketing and promotions, please see our Opt Out or Close Your Account section of this privacy statement.

5. How we store and retain your information

We store your data in databases and on storage servers in our own facilities, in colocation data centers, and in those of our contracted service providers. Your data may not be stored in the country in which you reside. We typically store our data in the U.S. If you live in the European Economic Area, please see our section for European Users.

We retain personal data for as long as necessary to fulfill any legal obligations we may have as well as for purposes of processing your information for the delivery of our services (for example, if you become a shareholder, we will need your information to email updates or account information to you). We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

6. Cookies and other technologies

Cookies contain bits of data that websites such as ours place on your computer’s hard drive for record keeping purposes. Cookies can make the web more useful by collecting and storing information about your preferences on a particular site and help websites operate more efficiently. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalized content.

We use our cookies:

(a) With the aim of optimizing our website and improving member experience. Cookies help us estimate our audience size, determine usage patterns and help us better target content and ads based on our users’ interests.

(b) We also use cookies so you can, for example, access any shareholder information you may be entitled to access.

(c) You have the option of not accepting the cookies we set. However, if you reject our cookies, you will not be able to take advantage of most of the features on our site, including subscription-based services.

Below you’ll find the types of cookies that we set when you visit mfamfunds.com and their purpose. To help you better understand why we’re setting them, we’ve used the categories and definitions set by the International Chamber of Commerce (“ICC”):

• Strictly Necessary: cookies that enable the services that you have specifically asked or paid for;
• Performance: cookies that collect information on how visitors use our site including the pages visited and most frequented as well as the sources of our traffic. They are used to help us improve how the site works;
• Functionality: cookies that help us remember the choices you have made so we can provide you with a more personalised experience; and
• Advertising: cookies used to deliver more relevant ads, and to make sure you don’t see the same adverts over and over again.

In addition to the cookies set directly by our partners, there are also cookies set by third parties to help deliver and monitor their ads. Please note we neither control nor have access to those cookies, and these advertisers’ uses of cookies are subject to their own privacy policies and not our policies.

If you follow links from our site to theirs, you should be aware that these other sites have their own privacy and data processing practices. We have no responsibility or liability for these independent policies. For more information regarding a site and its privacy policies including its use of cookies, check that site.

7. Cookie Removal and More Information

You can always modify your browser so as not to accept cookies or to notify you when cookies are sent to it. For more information about cookies including removing any or all of your cookies, please visit http://www.allaboutcookies.org.

Also, if you would like to remove the Google Analytics and DoubleClick cookies, please go to  http://tools.google.com/dlpage/gaoptout and

http://www.google.com/ads/preferences/plugin/ respectively. You should be aware that this will affect your Google cookies on all sites, and not just ours.

8. Opt Out or Close Your Account

1. Marketing & Promotions. If you would rather not hear from us by email, you can object to further marketing at any time by: (i) selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you; or (ii) sending us an email to DPO@mfamfunds.com.
   
   Please note: If you are a subscriber, please note that clicking the “unsubscribe” link will not cancel your investment advisory agreement, but it is likely to affect deliverability of your newsletter messages, announcements, or other product related communications. If you become a shareholder, or if you register for an account with us, we may contact you to confirm your subscription details, or registration, or to provide you with information about its terms or features. You may wish to keep these transactional or relationship emails, to help you use our products and services.

2. Behavioral Advertising. To learn more about this behavioral advertising, including information on how to opt-out, please:
   
   (a) visit the DAA opt-out program, the Evidon opt-out program, and the Google Analytics opt-out program to learn how to opt out of having your information collected in browsers for ad serving purposes;
   
   (b) download the Evidon Ad Control application, available for iOS and Android, to learn how to opt out of having your information collected in mobile apps;
   
   (c) see the interests associated with you by Google at https://adssettings.google.com; and
   
   (d) visit the Network Advertising Initiative’s opt out page.
   
   Please remember that some or all of these opt-out mechanisms use cookies to remember you have opted out, and if you delete cookies from your browser your opt-out will also be deleted.

3. Consent Withdrawal. Where the processing of your personal information by us is based on consent, you can withdraw consent at any time by: (i) using the “Update Your Preference” link in the email footer from MFAM Funds or (ii) contacting our Custodian, US Bank, at 1-888-863-8803 or https://www.mfamfunds.com/contact-us/
4. Close Your Account Permanently. If you want to close your account – i.e., so that it cannot be logged into – please contact us at dpo@mfamfunds.com.
5. Security and Protection of Your Information
   
   We are committed to protecting your personal information. All information that you provide to us is stored on our secure servers. Access to paid-for areas of the site, such as our newsletter services is password-protected for your privacy and security. While we do our best to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. What does all this mean? Just as in the investing world, you must protect yourself. You are responsible for maintaining the secrecy of your passwords and/or any account information. If you need to change your password, please follow the steps outlined below.
   
   Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
   
   Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

10. Users Aged 13 or Under

Protecting the safety of children when they use the internet is important to us.

The site is intended for use only by persons who are at least 13 years of age. By using this site, you confirm to us that you meet this requirement. If you are aged 13 or under, please get your parent/guardian’s permission beforehand whenever you provide personal information to our website. Users without this consent are not allowed to provide us with personal information.

If you are under the age of 13 your parent or guardian must consent on your behalf where we ask for consent in relation to the use of your information.

11. International Users

If you are a resident of the European Union or anywhere other than in the U.S., Motley Fool Asset Management services are available only to investors and prospective investors who reside in the United States (including the territories of Guam, Puerto Rico, and the United States Virgin Islands). MFAM generally does not manage money for individuals residing outside the United States, even if they are United States citizens or lawful permanent residents, except to investors with United States military APO or FPO addresses.

The information on this site is intended solely for U.S. residents. Nothing on the Motley Fool Asset Management site should be considered a solicitation in any jurisdiction where the offer, solicitation, purchase, or sale would be unlawful under the securities laws of such foreign jurisdiction or the United States.

12. Update or Correct Your Information

If you want to change your email address for delivery of your requested content, please use the “Update Your Preference” link in the email footer from MFAM Funds.    

13. Changes to this Privacy and Cookie Statement

We may amend this Privacy and Cookie Statement from time to time. Please check back regularly to review your rights and to check the Effective date or Last Updated date listed below. If we make any substantive changes to this policy, we’ll announce it on our site and notify you by email.

Contact Us

Questions, comments and requests regarding this privacy and cookie policy are welcomed and should be addressed to:

Data Protection Officer
Motley Fool Asset Management, LLC
2000 Duke Street
Suite 275
Alexandria, VA 22314

dpo@mfamfunds.com

Last Updated: January 1^st, 2020

Legal

• Contact Us

Our Regulatory Privacy Policy

The following Privacy Policy for MFAMFunds.com website users is presented by Motley Fool Asset Management and MFAM Funds (together, “we” “MFAM Funds,” or “us”). A privacy notice will also be included within the Annual Report for any MFAM Funds mutual fund, but this Privacy Policy (as modified from time to time through procedures described below) applies to investors (or potential investors) who use the FoolFunds.com website for information, subscriptions, or transactions.

We know that while you as investors (i.e., “you”) are entrusting us to manage your money, you are also entrusting us with the privacy and security of your personal information. We take that trust seriously.

As you may know, Motley Fool Asset Management, the investment advisor to MFAM, is a subsidiary of The Motley Fool Holdings, Inc., which also owns The Motley Fool, LLC (provider of Fool.com and several investment newsletter services), The Motley Fool Limited (provider of Fool.co.uk and several investment newsletters in the United Kingdom), and The Motley Fool Australia Pty LTD (provider of Fool.com.au in Australia). Together, these companies, with other affiliates, are the Motley Fool Companies. Please read this Privacy Policy in conjunction with the Privacy Policy for any other Motley Fool Companies of which you are a customer.

I. Why we obtain personal information about you

It should come as no surprise that we need personal information about our current, former, and prospective investors. We may use personal information about you, such as your name, address, phone number, Social Security number, assets, income, and date of birth, to accept your investment; service and maintain your account; process transactions in your account; respond to inquiries from you; develop, offer, and deliver products and services to you, including publications that we may email you; or fulfill legal and regulatory requirements.

II. Sources of personal information

We may collect the following public and non-public personal information about you:

• Information we receive from you on or in an application (even if you don’t complete or submit the application) or other forms, or from correspondence or conversations.
• Information we receive from you on or in our website, including your email address, or that we capture through Web pages.
• Information we receive through the use of “cookies” and similar data files, which are tiny files that we ask your browser to store. We may use such files to provide personalized features, understand how people are using our website, or make it easier for you to access your account. We don’t use them to obtain personal information from your hard drive. We will not share information from these files with others, except to help service your account.
• Information about your transactions with us, our affiliates, or others, including, but not limited to, your account number and balance, payments history, parties to transactions, cost-basis information, and other financial information.
• Information received from our introducing broker.
• Information from consumer reporting agencies or other references.

III. How we share information about you with third parties

We do not disclose any non-public personal information about current, prospective, or former investors, except as set out in this Privacy Policy (or required by law).

We may share personal information about you as follows:

• We may provide information to service providers, such as those that process transactions or otherwise help service or administer the fund or its investments (for example, the introducing broker, transfer agent, printing and mailing companies, parties that provide marketing services on our behalf, securities clearinghouses, and other entities that may provide services at our direction). Our service providers must agree to use the personal information we share with them only to provide the services we specify. Of course, when we need to send things to you, we may also need to disclose your information to a delivery or postal service.
• We may provide information to government agencies, other regulatory bodies, and law-enforcement officials (for example, for tax purposes or for reporting suspicious transactions).
• We may provide your information to other organizations, with your consent (for example, if you use us as a financial reference in applying for a financial product or service of another institution), or as permitted or required by law (for example, for fraud prevention).
• We may disclose your personal information to protect our rights or property, or our safety or that of others’.
• We may disclose your information to other Motley Fool Companies, as set out below.

IV. How we share information about you within the Motley Fool group of companies

We have arrangements with Motley Fool Companies to provide for investment management, distribution, and servicing, and we may exchange personal information about you with such affiliates. We may also exchange your personal information with our affiliates who act as our internal service providers to perform certain services and functions relating to your investment on our behalf — for example, printing, mailing, and data-processing services. We may also share certain personal information about you with Motley Fool Companies for their use in marketing products and services as allowed by law. If you do not want us to share the information accordingly, or if you want to opt out of receiving email marketing from Motley Fool Asset Management, you may do so here.

V. How we protect information about you

As further described below under “Our Security Policy,” we maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. We restrict access to personal information to those who require it to develop, support, offer, and deliver products, information, and services to you.